7 Stage 2 Final Rule: Overview Overview Updates to this rule apply to Eligibility, Stage 1 MU criteria and Stage 2 MU criteria IMPORTANT - Even though the Stage 2 Final Rule has been published, a number of the changes identified are not yet effective. Medical Assistance HIT Initiative 7

8 Stage 2 Final Rule: Overview Stage 1 vs. Stage 2 We are currently in Stage 1 of MU for the EHR Incentive Program for both EHs and EPs. Stage 2 MU goes into effect in 2014 If you have participated in the EHR Incentive Program in 2011 or 2012, it does not mean you will report on Stage 2 MU criteria for your next participation year Once you have completed 2 years of Stage 1 MU, you will then move to Stage 2 MU. If you have only completed 1 year of Stage 1 MU by 2014, you will report on Stage 1 MU again in 2014 Medical Assistance HIT Initiative 8

9 Program Update: Timelines Is it too late to get started? Not at all! Even though today s presentation is on MU Stage 2, eligible providers will always begin at the Stage 1 level. Each EP spends: 2 years in Stage 1 2 years in Stage 2 2+ years in Stage 3 The Medicaid incentive program runs through 2021 and lets EPs skip years if necessary. Medical Assistance HIT Initiative 9

10 Program Update: Timelines Stage 2 Implementation Timeline September 4th, Stage 2 Final Rule published Spring 2013, Pennsylvania implementing certain changes from the Stage 2 Final Rule January 2014, Stage 2 MU reporting requirements apply for EPs who have already completed 2 years of Stage 1 MU PA EHR HIT team to review updates to Final Rule and present overview to PA providers October 1, 2013, Stage 2 MU reporting requirements apply for EHs who have already completed 2 years of Stage 1 MU In 2014, all EPs & EHs will report on 90 days of MU regardless of which Stage you are participating Medical Assistance HIT Initiative 10

14 Stage 2 Final Rule: Adjustments Medicare Payment Adjustments In 2015, CMS s Medicare program will begin imposing payment adjustments for the Medicare claims for providers who have not demonstrated meaningful use in a previous payment year. Providers can demonstrate meaningful use through the Medicaid program in order to avoid the payment adjustments through Medicare. NOTE: Adopt, Implement & Upgrade does not count toward demonstrating Meaningful Use Payment adjustments do not affect provider types who are not eligible for the EHR Incentive program NOTE: To avoid Payment Adjustments: EPs MUST continue to demonstrate meaningful use every year to avoid payment adjustments in subsequent years. Payment adjustments begin in Payment Adjustment Year Full Year EHR Reporting Period (starting 2011 or 2012) MU Reporting Period (starting with 90 days in 2013) MU Reporting Period (starting with 90 days in 2014) (90 days) (90 days) Medical Assistance HIT Initiative 14 (90 days) (90 days)

15 Stage 2 Final Rule: Similarities Key Points That Did NOT Change Half of Outpatient Encounters at least 50% of EP outpatient encounters must occur at locations equipped with certified EHR technology. Denominators based on outpatient locations equipped with CEHRT and include all such encounters or only those for patients whose records are in CEHRT depending on the measure. CHIP Encounters In Pennsylvania, we can still NOT Accept CHIP encounters unless it s from an EP that practices predominately in a FQHC or RHC Program eligible provider types remain the same Medical Assistance HIT Initiative 15

16 Stage 2 Final Rule: Similarities EHR Incentive Program Eligibility 1. Program Eligibility is determined by the HITECH Act 2. There have been no changes to the HITECH Act 3. Therefore, the definitions of Eligible Professionals (EPs) and Eligible Hospitals (EHs) remain the same. Medical Assistance HIT Initiative 16

17 Stage 2 Final Rule: 2013 Updates Hospital-Based EP Change If a Hospital-Based EP can demonstrate that they fund the acquisition, implementation, and maintenance of CEHRT, including supporting hardware and interfaces needed for meaningful use without reimbursement from an eligible hospital or CAH in lieu of using the hospital s CEHRT they can be determined non-hospital-based & potentially receive an incentive payment. Process yet to be finalized. Medical Assistance HIT Initiative 17

18 Stage 2 Final Rule: Program Year 2013 Updates EHR Encounter Definition Update Current Encounter Definition Services rendered on any one day to an individual where Medical Assistance paid for part or all of the service or their premiums, co-payments and/or cost-sharing. New Encounter Definition* Services rendered on any one day to an individual enrolled in a Medical Assistance program. Zero-paid encounters can now be included in the patient volume calculations. Medical Assistance HIT Initiative *This change will be effective in Oct for EHs and Jan for EPs 18

19 Stage 2 Final Rule: Spring 2013 Updates EHR MA Patient Volume Calculations Current Patient Volume Calculations Currently, the 90 day patient volume calculations are collected from the previous calendar year for EPs and the previous federal fiscal year for EHs New Patient Volume Calculations* In 2013, CMS is allowing states to continue to use the same reporting period as before or there is now the option to use a 90 day period in the last 12 months preceding provider s attestation. Medical Assistance HIT Initiative *EPs will not have option to report with preceding 12 months until Spring

20 Stage 2 Final Rule: Program Year 2013 Updates EH Cost Data Update Current EH Cost Data Definition Use discharge data from the hospital fiscal year that ends during the Federal fiscal year which serves as the first payment year. New EH Cost Data Definition* Hospitals that begin participating in Federal Fiscal year 2013 or later can use discharge data from the most recently completely facility fiscal year. *This change will be effective in Oct for EHs Medical Assistance HIT Initiative 20

22 Stage 2 Final Rule: Spring 2013 Updates Optional Changes to Stage 1 Measure: eprescribing Core measure 4 (EP) Current Stage 1 Measure New Stage 1 Option Exclusion No Exclusion available Exclusion Permitted to take an exclusion if there is not pharmacy within a 10 mile radius of the EPs practice that accepts electronic prescriptions at the start of the reporting period This exclusion is available in Spring 2013 and beyond for Stage 1 Medical Assistance HIT Initiative 22

26 Stage 2 Final Rule: Spring 2013 Updates Changes to Stage 1: Public Health Objectives Menu measures 9 &10 for EPs and Menu measures 8, 9 & 10 for EHs Immunizations Reportable Labs Syndromic Surveillance Addition of except where prohibited to all three objectives This update will be available in Spring 2013 and beyond for Stage 1 This addition is for clarity purposes and does not change the Stage 1 measure for these objectives. Medical Assistance HIT Initiative 26

27 Stage 2 Final Rule: 2014 Updates Changes to Stage 1 Measures: E-Copy & Online Access Core measure 12 for EPs and core measure 11 for EHs Current Stage 1 Objective New Stage 1 Objective Objective = Provide patients with e-copy of health information upon request. Provide electronic access to health information Objective = Provide patients the ability to view online, download and transmit their health information The measure of the new objective is 50% of patients have accessed their information; There is no requirement that 5% of patients do access their information in Stage 1 The change in objective takes effect in 2014 to coincide with the 2014 certification and standards criteria. Medical Assistance HIT Initiative 27

28 Stage 2 Final Rule: 2014 Updates Upcoming 2014 Changes EHRs Meeting ONC 2014 Standards starting in 2014 all EHR Incentive Program participants will have to adopt certified EHR technology that meets ONC s Standards & Certification Criteria 2014 Final Rule Reporting Period Reduced to 90 Days to allow providers time to adopt 2014 certified EHR technology and prepare for Stage 2, all participants will have a 90 day reporting period in 2014 only. Medical Assistance HIT Initiative 28

29 Stage 2 Final Rule: 2014 Updates Upcoming 2014 Changes Exclusions starting in 2014 EPs and EHs will not be permitted to count an exclusion toward the minimum of 5 menu objectives on which they must report if there are other menu objectives which they can select/meet Medical Assistance HIT Initiative 29

30 Stage 2 Final Rule: 2014 Updates Clinical Quality Measures Update Although reporting CQMs is no longer a core objective of the EHR Incentive Programs, all providers are required to report on CQMs in order to demonstrate meaningful use. Beginning in 2014, the reporting of clinical quality measures (CQMs) will change for all providers In 2014 and beyond, reporting programs (i.e., PQRS, erx reporting) will be streamlined in order to reduce provider burden. EPs and EHs will need to begin reporting on the new CQMs in 2014 regardless of what MU stage they are in Medical Assistance HIT Initiative 30

31 Stage 2 Final Rule: 2014 Updates What Stage 2 Means to You New Criteria Starting in 2014, providers participating in the EHR Incentive Programs who have met Stage 1 for two or three years will need to meet meaningful use Stage 2 criteria. Improving Patient Care Stage 2 includes new objectives to improve patient care through better clinical decision support, care coordination and patient engagement. Saving Money, Time, Lives With this next stage, EHRs will further save our health care system money, save time for doctors and hospitals and save lives. Medical Assistance HIT Initiative 31

36 Stage 2 Final Rule: 2014 Updates Closer Look at Stage 2: Patient Engagement Patient Engagement engagement is an important focus of Stage 2 Requirements for Patient Action: More than 5% of patients must send secure messages to their EP More than 5% of patients must access their health information online Exclusions CMS is introducing exclusions based on broadband availability in the provider s county. Medical Assistance HIT Initiative 36

37 Stage 2 Final Rule: 2014 Updates Closer Look at Stage 2: Electronic Exchange Stage 2 focuses on actual use cases of electronic information exchange: Stage 2 requires that a provider send a summary of care record for more than 50% of transitions of care and referrals. The rule also requires that a provider electronically transmit a summary of care for more than 10% of transitions of care and referrals. At least one summary of care document sent electronically to recipient with different EHR vendor or to CMS test EHR. Medical Assistance HIT Initiative 37

38 Stage 2 Final Rule: 2014 Updates Stage 2 Core: EPs must meet all 17 objectives: Core Objective Measure 1. CPOE Use CPOE for more than 60% of medication, 30% of laboratory, and 30% of radiology 2. E-Rx E-Rx for more than 50% 3. Demographics Record demographics for more than 80% 4. Vital Signs Record vital signs for more than 80% 5. Smoking Status Record smoking status for more than 80% 6. Interventions Implement 5 clinical decision support interventions & drug/drug and drug/allergy 7. Labs Incorporate lab results for more than 55% 8. Patient List Generate patient list by specific condition 9. Preventive Reminders Use EHR to identify and provide reminders for preventive/follow-up care for more than 10% of patients with two or more office visits in the last 2 years Medical Assistance HIT Initiative 38

39 Stage 2 Final Rule: 2014 Updates Stage 2 Core: EPs must meet all 17 objectives: Core Objective Measure 10. Patient Access Provide online access to health information for more than 50% with more than 5% actually accessing 11. Visit Summaries Provide office visit summaries for more than 50% of office visits 12. Education Resources Use EHR to identify and provide education resources more than 10% 13. Secure Messages More than 5% of patients send secure messages to their EP 14. Rx Reconciliation Medication reconciliation at more than 50% of transitions of care 15. Summary of Care Provide summary of care document for more than 50% of transactions of care and referrals with 10% sent electronically and at least one sent to a recipient with a different EHR vendor or successfully testing with CMS test EHR 16. Immunizations Successful ongoing transmission of immunization data 17. Security Analysis Conduct or review security analysis and incorporate in risk Medical Assistance HIT Initiative 39 management process NEW

40 Stage 2 Final Rule: 2014 Updates Stage 2 Menu: EPs must select 3 of 6 objectives: Menu Objective Measure 1. Imaging Results More than 10% of imaging results are accessible through Certified EHR Technology NEW 2. Family History Record family health history for more than 20% NEW 3. Syndromic Surveillance Successful ongoing transmission of syndromic surveillance data 4. Cancer Successful ongoing transmission of cancer case information NEW 5. Specialized Registry Successful ongoing transmission of data to a specialized registry 6. Progress Notes Enter an electronic progress note for more than 30% of unique patients NEW NEW Medical Assistance HIT Initiative 40

41 Stage 2 Final Rule: 2014 Updates Stage 2 Core: EHs must meet all 16 objectives: Core Objective Measure 1. CPOE Use CPOE for more than 60% of medication, 30% of laboratory, and 30% of radiology 2. Demographics Record demographics for more than 80% 3. Vital Signs Record vital signs for more than 80% 4. Smoking Status Record smoking status for more than 80% 5. Interventions Implement 5 clinical decision support interventions + drug/drug and drug/allergy 6. Labs Incorporate lab results for more than 55% 7. Patient List Generate patient list by specific condition 8. emar emar is implemented and used for more than 10% of medication orders NEW Medical Assistance HIT Initiative 41

42 Stage 2 Final Rule: 2014 Updates Stage 2 Core: EHs must meet all 16 objectives: Core Objective Measure 9. Patient Access Provide online access to health information for more than 50% with more than 5% actually accessing 10. Education Resources Use EHR to identify and provide education resources more than 10% 11. Rx Reconciliation Medication reconciliation at more than 50% of transitions of care 12. Summary of Care Provide summary of care document for more than 50% of transitions of care and referrals with 10% sent electronically and at least one sent to a recipient with a different EHR vendor or successfully testing with CMS test EHR 13. Immunizations Successful ongoing transmission of immunization data 14. Labs Successful ongoing submission of reportable laboratory results 15. Syndromic Surveillance Successful ongoing submission of electronic syndromic surveillance data Medical Assistance HIT Initiative Security Analysis Conduct or review security analysis and incorporate in risk management process

43 Stage 2 Final Rule: 2014 Updates Stage 2 Menu: EHs must select 3 of 6 objectives: Menu Objective Measure 1. Progress Notes Enter an electronic progress note for more than 30% of unique patients 2. E-Rx More than 10% electronic prescribing (erx) of discharge medication orders 3. Imaging Results More than 10% of imaging results are accessible through Certified EHR Technology 4. Family History Record family health history for more than 20% NEW NEW NEW NEW 5. Advanced Directives Record advanced directives for more than 50% of patients 65 years or older 6. Labs Provide structured electronic lab results to EPs for more than 20% NEW Medical Assistance HIT Initiative 43

44 Stage 2 Final Rule: 2014 Updates Clinical Quality Measures Clinical Quality Measures provide statistics on high priority health conditions. In the future, these measures will help support pay for performance reimbursement models. (i.e. payments based on improvement in a population s health instead of the number of services performed.) There are multiple federal programs that require the reporting of clinical quality measures. To ease the burden of reporting, clinical measures will be aligned across programs as much as possible. Medical Assistance HIT Initiative 44

45 Stage 2 Final Rule: 2014 Updates Clinical Quality Measures Required 9 CQMs covering three domains (was 6 CQMs) There isn t a required core set. However, there are recommended core sets for adults and children; but only need to report if applicable to the EP s scope of practice. Regardless of the stage of meaningful use, all providers will need to submit 9 CQMs in CQMs aren t classified as Stage 1 or Stage 2. Medicaid providers will electronically report their CQM data to their state. Medical Assistance HIT Initiative 45

53 Stage 2 Final Rule: What to Expect What To Expect What are the next steps? MA EHR Incentive Program website will be updated with Stage 2 information ( Follow-up Webinar in early 2013 to show updates in MAPIR application Continuous updates on weekly ListServ messages Medical Assistance HIT Initiative 53

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